ML20246H733

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-458/88-26

ML20246H733
Person / Time
Site:	River Bend
Issue date:	05/04/1989
From:	Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Deddens J GULF STATES UTILITIES CO.
References
NUDOCS 8905160179
Download: ML20246H733 (2)

See also: IR 05000458/1988026

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In Reply Refer To:

Docket: 50-458/88-26

Gulf States Utilities

ATTN: fir. James C. Deddens

Senior Vice President (RBNG)

P.O. Box 220

St. Francisville, Louisiana 70775

Gentlemen:

Thank you for your letter of April 17, 1989, in response to our letter and

Notice of Violation dated March 17, 1989. We have reviewed your reply and find

it responsive to the concerns raised in our Notice of Violation. We will review

the implementation of your corrective actions during a future inspection to

determine that full compliance has been achieved and will be maintained.

Sincerely.

Onginal Signed Bp

t 3: CALLAN

L. J. Callan, Director

Division of Reactor Projects

cc:

Gulf States Utilities

ATTN: J. E. Booker, Manager-

River Bend Oversight

P.O. Box 2951

Beaumont, Texas 77704

Gulf States Utilities

ATTN: Les England, Director ,

Nuclear Licensing - RBNG  !

P.O. Box 220

St. Francisville, Louisiana 70775

Louisiana State University,

Government Documents Department

Louisiana Radiation Control Program Director

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GULF STATES UTILITIES COMPANY

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RIVER DEND STATION POST OFFICE 80x 220 ST FRANCISVILLE. LOUISIANA 70776

ARE A CODE 604 636 6094 346 8661

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April 17, 1989 N I

RBG-30552 jj

File Nos. G9.5, G15.4.1

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U. S. Nuclear Regulatory Commission

Document Control Desk

Washington, D.C. 20555

Gentlemen:

River Bend Station - Unit 1

Refer to: Region IV

Docket No. 50-458/ Report 88-26

Pursuant to 10CFR2.201, this letter provides Gulf States

Utilities Company's (GSU) response to the Notice of Violation for

NRC Inspection Report No. 50-458/88-26. The inspection was

performed by Messrs. E. J. Ford and W. B. Jones during the period

of December 1 - 31, 1988 of activities authorized by NRC

Operating Licensing NPF-47 for River Bend Station - Upit 1.

GSU's response to the violations are provided in the attachments.

This completes GSU's response to these items.

Should you have any questions, please contact Mr. L. A. England

at(504)381-4145.

S ncerely

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/ . C. Deddens

Senior Vice President

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River Bend Nuclear Group

JEB/LAE/RJK/JWC/ch

cc: U. S. Nuclear Regulatory Commission

Region IV

611 Ryan Plaza Drive, Suite 1000

Arlington, TX 76011

NRC Senior Resident Inspector

P. O. Box 1051 i

St. Francisville, LA 70775  ;

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UNITED STATES OF AMERICA

NUCLEAR REGULATORY COMMISSION

STATE OF LOUISIANA )

PARISH OF WEST FELICIANA )

In the Matter of ) Docket No. 50-458

50-459

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GULF STATES UTILITIES COMPANY )

(River Bend Station,

Unit 1)

AFFIDAVIT

J. C. Deddens, being duly sworn, states that he'is a

Senior Vice President of Gulf States Utilities Company; that.

.he is authorized on. the part of said company to sign and

file with the Nuclear Regulatory Commission the documents

attached hereto; and that all such documents are true and

correct to the best of' his knowledge, information' and

belief.

D * * > --

J.#C. Deddens

Subscribed and sworn to before me, a Notary Public in

and for the State and Parish above named, this [7Ybdayof

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Middlebrooks

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/J otary Public in and for

West Feliciana Parish,

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Louisiana

My Commission is for Life.

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ATTACHMENT 1

Response to Notice of Violation 50-458/8826-01

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Level IV Violation

REFERENCE:

1. Notice of Violation - Letter from R. D. Martin to to J. C. Deddens, dated

March 17, 1989.

2. Licensee Event Report No.88-027 - to NRC from J. E. Booker, dated January

18, 1989

FAILURE TO ENSURE RCIC SYSTEM OPERABILITY:

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RBS Technical Specifications (TS) Limiting Condition for Operation (LCO)

3.4.7.3 requires that the reactor core isolation cooling -(RCIC) system be

operable in Operational Conditions 1, 2, and 3 with reactor steam dome

pressure greater than 150 psig.

Contrary to the above, RBS was operated in Operational Conditions 1, 2, and 3

during the period November 1985 to December 19, 1988, with the RCIC system

inoperable. .The RCIC system was considered inoperable because the turbine

configuration was not in accordance with the seismically tested-design

configuration.

REASON FOR VIOLATION:

During a review by the Design Engineering group to prioritize outstanding

modification packages it was noted that the installation of the RCIC system

turbine was not completed per design. Contrary to its seismic qualification

requirements, an oil piping support addition had not been completed, the

coupling pedestal bolting had not been lockwired, and the pedestal dowel pins

were not in place.

Investigation of historical documents shows that the portion of the original

modification to install the lock wire and dowel pins was completed. However,

in a subsequent realignment of the turbine, the dowel pins would no longer

fit. A new modification using new dowel pin locations .was initiated to

complete the original modification. This MR was found not to be worked.

The scope of the management effort to reduce the backlog level of

unprioritized MRs was established in response to two primary actions:

(1) corrective action to NRC Inspection Report 88-01, to review all MRs

generated as a result of corrective actions identified on condition reports

and provide recommendations for prioritization (schedule) by 12/31/88, and (2)

a commitment to.the Institute of Nuclear Power Operations (INP0) to have the

. backlog of unprioritized MRs reduced to a manageable level by the end of 1988.

The subject MR was not initiated as a result of the condition report program;  ;

it was a construction modification which was included in the balance of the i

reduction effort. All modifications as a result of condition report

corrective actions have been reviewed and prioritized. Less than 75

modification requests remain in the balance of the program. These 75 MRs have

been screened by Design Engineering and none have been determined to have an

impact on operabili^.y.

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Tfie root cause of this event appears to have been an oversight in identifying

the operability impact of not performing this modification. Due to the large

backlog of incomplete construction modifications that existed at the time, the

potential significance of this MR did not surface quickly.

CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND RESULTS ACHIEVED:

The RCIC system was declared inoperable at 1700 on December 19, 1988. A

condition report was written and the proper installation was completed on

December 24, 1988. After satisfactory retest, the RCIC system was restored to

operable status at 1245 on December 24, 1988.

As identified above, the inadequate installation was initially identified as a

direct result of an internal audit of incomplete construction modifications.

All open MRs which have not been prioritized have been screened by Design

Engineering and none have been determined to have an impact on operability.

The identification of this deficiency and subsequent corrective action is

indicative of GSU's improvement in the MR document control and administrative

control areas. This review also confirmed that the operability oversight for

incomplete construction modifications which had been tracked on system punch

lists was isolated.

An assessment of the safety implications have shown the effects of the

incomplete construction modification to be minimal. The RCIC system provides

redundancy to ttle high pressure core spray system (HPCS) for long term core

cooling following a postulated control rod drop accident (CRDA). The RCIC

system is not required to function ir, this emergency safety feature (ESF)

capacity since the RBS design includes an automatic depressurization system

(ADS). ADS provides the required redundancy to HPCS.

No operability or functional problems related to this incomplete modification

have been identified. Operation of the RCIC turbine and pump for quarterly

surveillance test procedures, both before and after completion of the

modification, has been acceptable. Additionally, the RCIC system has

experienced two automatic initiations and in each case the RCIC system

performed as designed. Therefore, the operability of the RCIC system under

normal plant conditions without a seismic event is not questionable.

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l Seismic qualification tests were conducted on the prototype test turbine at

much higher accelerations than those assumed for RBS for either an operata.g

basis earthquake (0BE) or safe shutdown earthquake (SSE). Also, part of these

tests was conducted with smaller dowel pins and without bolt locking and oil

piping supports. The satisfactory performance of the prototype test turbine

in this configuration indicates that the RBS installation would r.ot have

failed in an OBE or SSE. The probability of simultaneous occurrence of a

seismic event and a CRDA with off-site power unavailable and HPCS inoperable

is approximately 10(-7) per reactor year,

i The RCIC system has demonstrated its ability to perform under normal plant

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conditions without a seismic event. Additionally, an evaluation comparing the

as-found installation with the original seismic qualification tests indicates

that the RCIC system would not have failed during a seismic event. Therefore,

the safe operation of the plant and the health and safety of the public were

not adversely affected as a result of this event. (For additional details of

assessment of safety implications, refer to Reference 2.)

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CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:

' A comprehensive review of the configuration management program at RBS has

shown that it is now thorough and effective. The current process for review

and prioritizing MRs is designed to assure that plant operability _

' considerations'are factored into the final schedule decisions and that the MRs -

are prioritized for implementation accordingly.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:

RBS is currently in full compliance.

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ATTACIMENT 2

Response to Notice of Violation 50-458/8826-02

Level IV Violation

REFERENCE:

Notice of Violation - Letter from R. D. Martin to to J. C. Deddens, dated

March 17, 1989.

-FAILURE TO SECURE A VHRA ACCESS DOOR:

RBS TS 6.12.2 requires that accessible areas with radiation levels, such that

a major portion of the body could receive in I hour a dose greater than 1000

mrem, shall be provided with locked doors to prevent unauthorized entry and

the keys shall be maintained under the administrative control of the control

operating foreman (C0F) on duty and/or the radiation protection supervisor. ,

Doors shall remain locked, except during periods of access under an approved  :

radiation work procedure (RWP) that specifies the dose rate levels in the

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immediate work area and the maximum allowable stay time for individuals in

that area.

Radiation Protection Procedure RPP-0005, " Posting of Radiologically Controlled

Areas," Revision 5, paragraph 7.4, requires that very high radiation area

(VHRA). entrances be locked and remain locked, except during periods of access

under an approved RWP. Doors must be locked or attended at all times.

Contrary to the above, on December 3,1988, from approximately 7:45 a.m. to

4:30 p.m. (CST), turbine building door TB 123-20, which provided access to a

VHRA around the moisture separator reheater tank, was not properly secured.

TB 123-20 was not attended during the period the door was left unsecured.

Seven cdditional examples of events where VHRA access doors were previously

left unsecured are identified in NRC Inspection Report 50-458/88-26.

REASON FOR VIOLATION:

During normal full power operations, fifty-six (56) doors must be controlled

as VHRAs. Locks for all VHRA doors may be opened by one of a limited number

of identical keys. The Shift Supervisor and the COF are issued a key for

emergencies only, and radiation protection (RP) personnel maintain control of

seven keys for their use. The key checkout method only identified who checked

out these keys -- not which doors were opened. However, persons checking out

these keys were required to read a statement of their responsibilities with

the use of VHRA keys which includes ensuring that the door must be left locked

and secured upon exit.

Investigation was inconclusive as to who failed to ensure that these doors

were secured upon exiting. The root causes of this problen are the failure on

the part of the individual to verify that the doors were secured and

ineffective controls to prevent recurrence.

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CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND RESULTS ACHIEVED:

All VHRA doors were locked upon discovery.

Numerous programmatic controls and corrective actions have been implemented

since initial plant operation to ensure that these doors are secured upon

exit. Increasingly stringent controls failed to produce the desired result.

On December 7, 1988, the Plant Manager issued memorandum TFP-251-88 to

supervisors emphasizing the serious nature regarding VHRA doors and

establishing more stringent administrative guidelines for routine access to

VHRAs. On December 9, 1988, procedure RPP-005, " Posting Radiologically

Controlled Areas", was revised by TCN 88-0782 to incorporate the Plant

Manager's guidelines. The changes that were implemented require that 1) only

radiation protection personnel will be issued keys to VHRA doors for routine

access, 2) RP personnel will log the opening and locking of VHRA doors and is

responsible for verification of locked doors, 3) for those entries without

constant RP coverage, a double verification is required upon exit to assure

that the door is locked, 4) RP personnel will daily physically check and

verify that all VHRA doors are locked and 5) an operability verification of

accessible VHRA doors will be performed monthly.

In addition to the above, Security also physically verifies twice daily that

accessible VHRA doors are locked.

CORRECTIVE, STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:

No VHRA doors have been discovered unsecured and unattended since the

implementation of the present program.

The improved, more stringent administrative controls established for routine

access to VHRA should prevent any future violations.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:

RBS is currently in full compliance.

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ATTACMENT 3

Response to Notice of Violation 50-458/8826

Level IV Violation

REFERENCE:

Notice of Violation - Letter from R. D. Martin to to J. C. Deddens, dated

March 17, 1989.

VIOLATION C:

10CFR 50.73 requires licensees to submit licensee event reports (LERs) to NRC

within 30 days of the discovery of events which are described in this

regulation. Among the events licensees are required to report is "Any

operation or condition prohibited by the plant's Technical Specifications ..."

RBS TS 6.12.2, "High Radiation Area," states that, " areas with radiation

levels such that a major portion of the body could receive in I hour a dose

greater than 1000 mrem shall be provided with locked doors ..." and that the,

" doors shall remain locked except during periods of access under an approved

RWP ..."

Contrary .to the above, on at least seven occasions between June 1987 and

December 1988, doors to VHRAs were found unlocked, a condition prohibited by

the plant's TS, and LERs were not submitted to NRC within 30 days of.the

discovery of these events.

REASON FOR THE VIOLATION:

GSU has previously interpreted NUREG-1022, " Licensee Event Reporting System",

such that violation of this administrative section of the TSs need not be

reported since the condition does not affect plant operation.

CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND RESULTS ACHIEVED:

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Condition reports will continue to be utilized to identify these events, and

RP management will now ensure that events related to TS section 6.12.2 are

reported under 10 CFR 50.73 requirements.

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CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS: l

A copy of this violation including the response will be routed to Shift

Supervisors, Radiation Protection, Licensing, QA, ISEG, and Compliance group

supervisors to inform these individuals of the reporting requirements

regarding discovery of unlocked VHRA doors.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:

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The appropriate RBS supervisors as identified above will be informed by May

15, 1989 of the deportability of these events.

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